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HMRC internal manual

VAT Business/Non-Business Manual

Clubs and associations: National Trust

The National Trust is the custodian and owner of numerous properties throughout the UK that are preserved as part of the national heritage. These properties include:

  • buildings
  • estates
  • open land; and
  • stretches of coastline.

The Trust also performs a mixture of business and non-business activities.

There are seven categories of National Trust membership:

  • individual
  • family
  • under-21 groups
  • corporate
  • junior
  • life and
  • benefactor.

The benefits include free entry to various premises, a newsletter and an annual report. HMRC accepts that subscriptions include a donational element. This can be calculated as explained in VBNB60550.

The taxable elements are the free entry and literature. A residual donational element remains when these have been valued and deducted from the subscription. The calculation is performed annually and the taxable proportions of the subscriptions adjusted accordingly.

Non-membership business activities include:

  • admission for a charge;
  • sales of goods and meals;
  • sales from managed estates (such as timber); and
  • the renting of properties.

The principal non-business activity is the care and management of areas for which no admission fees are charged. No input tax is deductible in respect of such areas unless they are used to generate taxable sales, for example timber.